G.R. No. 214470 , December 07, 2016
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. JESUS MAYOLA Y PICAR, ACCUSED-APPELLANT.

FACTS

Accused-appellant Jesus Mayola y Picar is the father of the private complainant, AAA. They lived with AAA’s three siblings in a single-room house. Their mother worked in Manila. AAA testified that the appellant had sexual intercourse with her every other day since 2001 when she was 13 years old. Her mother knew but was afraid to report it. On the evening of December 30, 2004, while AAA and her siblings were asleep, appellant went on top of her and inserted his penis into her vagina, stopping only when her brother woke up. Appellant then called AAA to a makeshift bed at the back of their house, which she heeded while crying. Fed up, AAA eventually reported the incident to the police, accompanied by her sister BBB, FFF, and uncle GGG. A medical examination on January 2, 2005, revealed nonporous introitus and old hymenal lacerations. An Information for qualified rape was filed. The RTC found appellant guilty beyond reasonable doubt and sentenced him to reclusion perpetua, with damages. The CA affirmed the conviction with modification on the damages. Appellant appealed, arguing his guilt was not proven beyond reasonable doubt, questioning AAA’s behavior (sleeping beside him and delay in reporting) and alleging ill-motive from his children due to his severe punishments.

ISSUE

Whether the guilt of the accused-appellant for the crime of qualified rape has been proven beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the CA decision. All elements of rape under Article 266-A(1)(a) of the Revised Penal Code were present: (1) carnal knowledge of a woman, and (2) accomplished through force, threat, or intimidation. AAA’s positive, clear, and straightforward testimony, corroborated by medical findings of old hymenal lacerations, sufficiently established carnal knowledge. As AAA’s father, appellant’s moral ascendancy substituted for violence or intimidation. The Court rejected appellant’s arguments: the victim’s behavior (sleeping beside the appellant and delay in reporting) does not negate rape, as there is no standard behavioral response for victims, especially when the rapist is a parent with moral influence. Delay in reporting does not equate to a false accusation. The alleged ill-motive was insufficient to overcome AAA’s credible testimony. The CA’s modification of damages was sustained. Appellant was found guilty of qualified rape and sentenced to reclusion perpetua without eligibility for parole, and ordered to pay civil indemnity, moral damages, exemplary damages, with interest.